RYA:

[john_morris_uk]

They had to write a syllabus in a word document and now keep some names on a list. For that investment they get £40 a time for posting a card.

How can I respectfully say that is one of the silliest posts I've seen. Please see my previous post about costs. If you can employ someone to issue these certificates and make the large profits that you seem to imply are being made, then perhaps you can explain how? It costs money to employ someone to administer the ICC and I don't believe anyone believes that the RYA are making large profits from their 'free to members and £40 to non members' charges.

Disclosure:

As anyone who checks my personal details will see, I do work for the RYA from time to time but I ought to point out that I don't represent the RYA with my views and am certainly not intimately familiar with their working costs and profit and loss etc. I am just trying to take a common sense view of the matter.

 

[toad_oftoadhall]

A policy in line with other certificates of competence issued by the MCA would make sense.

Sounds very plausible, except for the fact you have show some sea time at CPE for the MCA certs. The lack of requirement to show sea time utterly negates any similar need to renew the ICC. In spite of that it still sounds very plausible, and I appreciate you pointing it out. Be nice to find out if that theory's correct.

Even so £40 for posting a letter is probably literally a better return per unit than printing £20 notes!

 

[toad_oftoadhall]

you can explain how?

Someone give's you £40 to send them a card and you can't see how that makes money?

Moonpig do the same for £3 a time!

Do you really think there the DVLA incur £40 per unit costs sending out tax discs?

None of which is relevant to the point under dispute - which you claimed you no longer disputed!

 

[john_morris_uk]

Even so £40 for posting a letter is probably literally a better return per unit than printing £20 notes!

Its completely disingenuous to say that its £40 for posting a letter, but admitting that would be inconvenient for your attitude to the RYA.

I suspect that if the RYA were to find a way of turning seawater into gold, then you would find some way of claiming it was all a con.

 

[toad_oftoadhall]

Its completely disingenuous to say that its £40 for posting a letter

I've written: "They had to write a syllabus in a word document and now keep some names on a list. For that investment they get £40 a time for posting a card.".

You know I wrote that because you quoted it!

But, yes after the capital costs they are getting cash for stuffing an envelope and posting it 2nd class, and they could wipe that step out by letting people print their own.

But what's your point? Are you suggesting there's something wrong with firms having high margins for some products? Why?

 

[john_morris_uk]

I've written: "They had to write a syllabus in a word document and now keep some names on a list. For that investment they get £40 a time for posting a card.".

You know I wrote that because you quoted it!

But, yes after the capital costs they are getting cash for stuffing an envelope and posting it 2nd class, and they could wipe that step out by letting people print their own.

But what's your point? Are you suggesting there's something wrong with firms having high margins for some products? Why?

But some of your criticism was that you were suggesting that it was the RYA who were profiteering. Which way are you arguing now? As I have said several times now, the costs of stuffing an envelope and posting it are rather more than the costs of the envelope and the printing etc. You need to pay someone to do it, keep records, and sort out the employees NI and pension and pay for an office and all the overheads that go with that etc etc. Therefore I have argued that free to members and £40 to non members is a reasonable price and whilst I have no problem in firms making money, I have argued that the RYA is NOT making lots of money from the ICC scheme.

I note you have cited Moonpig and the DVLA. Both of these are spurious. Printing a card off the web is not the same as the RYA having the overheads of administering the ICC scheme on behalf of the government etc. DVLA costs millions to run and has the benefits of scale and a national data base.


I know you seem to have a complete and utter aversion to the RYA. Many would see your attitude as irrational but its a free country. However whether you like it or not, the RYA is a member organisation that is tasked to perform some official duties. I have argued that I believe them to act reasonably in the performance of their duties and I don't understand your complaint.

 

[toad_oftoadhall]

I'm going to play fallacy bingo!!!

Here we go:

But some of your criticism was that you were suggesting that it was the RYA who were profiteering.

Straw man fallacy.

I know you seem to have a complete and utter aversion to the RYA.

Appeal to motive.

Many would see your attitude as irrational but its a free country.

Argumentum ad populum.

However whether you like it or not, the RYA is a member organisation that is tasked to perform some official duties.

Ignoratio elenchi & Appeal to motive.

your complaint.

Straw man fallacy.



House!

 

[Sybarite]

For info: http://www.plaisances.info/reglemantations/icc

 

[toad_oftoadhall]

For info: http://www.plaisances.info/reglemantations/icc

Many thanks for that.

Can someone who reads French a little more reliably than me say if this:

"En conséquence, les bateaux de plaisance d’une longueur maximale de 15 mètres, transportant moins de 15 personnes, et conçus pour circuler normalement à une vitesse inférieure à 20 km/h, désignés par le terme de « coches de plaisance », peuvent circuler librement sur les eaux intérieures de la zone définie par l’arrêté ministériel du 17 mars 1988 s’ils sont munis du certificat international pour les bateaux de plaisance de navigation intérieure délivré conformément aux dispositions de la résolution no 13, révisée, par tout État ayant accepté ladite résolution."


...means that nobody from a country that doesn't issue ICCs can travel on the inland waterways specified on this page on their own boat?

I know people that have so I've always assumed there must be some mechanism, perhaps not.

 

[chinita]

RYA having the overheads of administering the ICC scheme on behalf of the government etc.

Am I missing something?

Does the government now require us to have an ICC - for whatever purpose?

No, but the RYA would like us to believe that.

The RYA is a wonderful business model. It has the cachet of 'Royal' - why? I don't know. It is a Company Limited by Guarantee, not an arm of the British Government, or a charity, or a professional body. It is simply a commercial entity.

 

[Tranona]

Please provide details of the number of other ways. It interests me and www.vnf.fr is remarkably silent on the topic of exactly what personal qualifications they require. I'm starting to wonder if it's just like the hire boats, someone just spends 5 minutes watching private boat owners steer and signs you off as capable FOC!



They had to write a syllabus in a word document and now keep some names on a list. For that investment they get £40 a time for posting a card.

Please read the RYA site for a list of qualifications that are eligible for an ICC. In addition to those cited there you can get one through the BSAC in the UK. Other countries also issue ICCs based on their own national qualifications. It is little to do with VNF, but the requirements are determined by CEVNI - which of course you would know if you read the material from the RYA on the origins of the ICC. Please keep up if you wish to make any contribution to this particular aspect of the debate.

All one can say is that it is good that you are not in charge of running an organisation if you have such a simplistic view of the world. Anyway, why are you bothered about how much the RYA charge for the service. If you were a member you would want them to charge the highest rate possible so that you do not subsidise non members and that you are sure they make a contribution towards providing the service. If you are a non member you make your own assessment as to whether it is of value to you - and as you keep asserting purchase of the certificate is entirely optional so the choice is up to you. If you don't think it is of value you don't have to buy it. If you need it that is the price - become a member and receive it as one of the membership benefits or pay the non member price.

Uricanejack has explained the origin of the 5 year renewal - but of course you knew that having been told about it on a number of occasions in the past by both myself and others. He is wrong of course in saying that renewal involves reassessment, and that probably means there is a case for relaxing that condition. However that is for the MCA to decide, assuming it is now allowed under the UN Resolution.

Don't you think, Toad, it is about time you stopped all this nonsense? You are on a loser - the old phrase about when you are in a deep hole stop digging. Every time you respond you further expose your ignorance and make yourself look a fool by trying create problems that simply do not exist in the real world - only in your imagination.

 

[Tranona]

Am I missing something?

Does the government now require us to have an ICC - for whatever purpose?

No, but the RYA would like us to believe that.

The RYA is a wonderful business model. It has the cachet of 'Royal' - why? I don't know. It is a Company Limited by Guarantee, not an arm of the British Government, or a charity, or a professional body. It is simply a commercial entity.

Oh dear Chinita! you are falling into the same trap as Toad - placing your own distorted interpretation on reality. You are missing something.

Please read the RYA material on the origin of the ICC and its status. There is nothing misleading about it. The RYA does not try to make you believe that the government requires an ICC, nor that there is any compulsion to have one.

The only reason the "government" in this case the MCA gets involved is because the UN Resolution gives governments the responsibility to issue internationally recognised certificates of competence. In the UK they authorise the RYA to do this on their behalf in just the same way that they authorise the RYA to run the approved qualifications for leisure craft.

Governments in some other countries issue the certificates directly because they issue their own licences directly and others delegate the responsibility to similar organisations to the RYA.

Is it really so difficult to accept simple explanations rather than make up your own as if there was some kind of conspiracy to hide a hidden truth?

 

[john_morris_uk]

Am I missing something?

Does the government now require us to have an ICC - for whatever purpose?

No, but the RYA would like us to believe that.

The RYA is a wonderful business model. It has the cachet of 'Royal' - why? I don't know. It is a Company Limited by Guarantee, not an arm of the British Government, or a charity, or a professional body. It is simply a commercial entity.

The simple answer would be to suggest that you read the thread.

There are many countries where they have compulsory licensing for people who wish to take boats to sea and since we don't have any form of licensing the ICC has been negotiated as the minimum documentation for non-nationals who are visiting to demonstrate that they are competent. See the web page for a fairly full explanation: http://www.rya.org.uk/infoadvice/boatingabroad/icc/Pages/icc.aspx

I have no idea where you get the idea from that the RYA would like us to believe that the government requires us to have an ICC - the RYA is explicit in saying its not legally necessary for many countries (let alone the UK) since many have not fully ratified Resolution 40. However some countries might require you to show some evidence of competence but the ICC doesn't allow you to avoid all local rules and regulations.

The RYA (as the national body for nearly all forms of watersports) are given authority to administer the ICC by the the government. Or would you prefer that the government sets up its own licensing department?

edit: I note that others have said almost exactly the same thing in the time I took to respond overnight!

 

[toad_oftoadhall]

RYA is explicit in saying its not legally necessary for many countries

Yes, which is misleading to the point of being a lie by omission since there are NO countries where it's legally required for visiting boats and that sentence strongly implies there might be some! This is EXACTLY what I meant when I said the web info was unclear and intended to encourage ICC sales.

if you want a CEVNI certificate you have to meet the minimum requirements of the ICC - which can be done in a number of ways

Please provide details of the number of other ways. It interests me and www.vnf.fr is remarkably silent on the topic of exactly what personal qualifications they require. I'm starting to wonder if it's just like the hire boats, someone just spends 5 minutes watching private boat owners steer and signs you off as capable FOC!

Please read the RYA site for a list of qualifications that are eligible for an ICC.

Your statement was nothing to do with ICCs. You've written there are "a number of ways" to get a qual that meets the Cevni inland waterways requirements. Your claim must be true otherwise 90pc of the world wouldn't be able to take their boats on CEVNI waterways. Don't be shy, tell us the number of ways the vast majority get their CEVNI quals without ever needing an ICC.

Uricanejack has explained

No he hasn't. He's offered a very plausible sounding guess which I appreciate him offering but he says he doesn't know. If Uricanejack's guess is right perhaps the RYA should make it absolutely clear that another body has forced them to take £40 every five years against their will! It could go on their clear website. Not that it matters since the dispute is whether or not ICCs are a cash-cow for the RYA, not whether they chose to have a cash cow!



Can someone find me a list of quals that allow someone from a nation does not issue ICCs to travel on a pleasure boat on CEVNI Canals. There must be a mechanism for the (majority) non ICC world to travel on CEVNI waters, just as there is a mechanism to allow hire boaters to travel on the CEVNI waters. I'd like to know what it is.

 

[AMCD300]

Why not just write to the UN - they have lots of highly paid people just itching to get stuck in to your enquiry.

 

[Tranona]

Yes, which is misleading to the point of being a lie by omission since there are NO countries where it's legally required for visiting boats and that sentence strongly implies there might be some! This is EXACTLY what I meant when I said the web info was unclear and intended to encourage ICC sales.



Your statement was nothing to do with ICCs. You've written there are "a number of ways" to get a qual that meets the Cevni inland waterways requirements. Your claim must be true otherwise 90pc of the world wouldn't be able to take their boats on CEVNI waterways. Don't be shy, tell us the number of ways the vast majority get their CEVNI quals without ever needing an ICC.



No he hasn't. He's offered a very plausible sounding guess which I appreciate him offering but he says he doesn't know. If Uricanejack's guess is right perhaps the RYA should make it absolutely clear that another body has forced them to take £40 every five years against their will! It could go on their clear website. Not that it matters since the dispute is whether or not ICCs are a cash-cow for the RYA, not whether they chose to have a cash cow!



Can someone find me a list of quals that allow someone from a nation does not issue ICCs to travel on a pleasure boat on CEVNI Canals. There must be a mechanism for the (majority) non ICC world to travel on CEVNI waters, just as there is a mechanism to allow hire boaters to travel on the CEVNI waters. I'd like to know what it is.

Why are you incapable of understanding plain English? Why do you say the RYA is "telling a lie by omission" when there is no omission. It is only your warped interpretation that turns statements that are true into lies, compounded by your lack of understanding of language.

You asked for ways in which you can get a CEVNI certificate without an ICC and I have told you. You fail to understand that the CEVNI requirements are in two parts, the test of practical competence and the test of regulations. The first is met by either a recognised qualification, which in some countries is their compulsory licence OR an ICC issued following a specific test covering the competences required by the UN Resolution 40. You have asked for ways of getting an ICC in the UK and I have referred you to the list on the RYA site. If you want to make up a list of how you can get a CEVNI certificate in other countries then do your one work and write to the UN, CEVNI and all the countries that you are interested in. I fail to see why the RYA or MCA need to provide such a list as it is of no relevance to UK citizens.

Uricanejack's explanation is correct. If you think it is a "guess" then it is no different from your guesses that you offer as facts to be dismissed - which as we have seen is very easy to do. I have told you many times that if you want to find out if this restriction is still relevant then you need to ask either the UN or the MCA. Pointless you speculating here without checking the position with the relevant authorities.

Why are you constantly using sloppy ill defined terminology in your questions? If you are using "cash cow" with the OED definition all you are questioning is whether the price charged for the service is at least equal to or exceeds the cost of providing it - that is it makes a "profit". As a member of the RYA I hope it does. As a taxpayer I also hope it does as it would be unreasonable for the taxpayer to subsidise something that is only of benefit to the individual. Do you have an alternative proposal for funding the certificate? The "dispute" about whether the ICC is a "cash cow", however it is defined exists only in your mind and if you want to resolve that dispute to your satisfaction then you need to first be clear about your definition and then you need to collect the data on costs and revenues to test out whether the "profit" meets your definition or not. Until then any statement you make on the subject is just meaningless words.

I think that covers all your issues. Lot of work for you to do to satisfy your need for further information - writing to the UN, writing to CEVNI, plus letters to approximately 150 countries to compile your list. Only you can do this as it is only you that needs the information. Asking others to do your work for you is an insult, although it does suggest that you consider yourself incapable of doing it. Write to the RYA and the MCA seeking clarification of the 5 year renewal rule. If you find that the 5 year rule is not compulsory then I am happy to support you in lobbying the MCA to get it changed, even though it would be of no benefit to me (or to you). I can also give you the benefit of my professional skills in checking your calculations of the "profit" made on the issuing of ICC certificates and advise if they meet any of the definitions of "cash cow".

 

[toad_oftoadhall]

Just thinking aloud but....

...requirement for ICC+CEVNI seems absent from the information for tourists here (unless navigation permit or sea permit need it):

http://www.vnf.fr/vnf/img/cms/Tourisme_et_domaine/tarif_plaisance_ang_201112131034.pdf

http://www.vnf.fr/vnf/img/cms/Domaine_public_fluvial/hidden/beforeyouleave_200509141429.pdf

Indeed, here it says the requiremnt for qualifications can be waived. No idea if that's relevant, I wonder if some/all waterways waive the requirement for pleasure boats on request?

http://www.unece.org/fileadmin/DAM/trans/doc/finaldocs/sc3/TRANS-SC3-115r2e.pdf

Of course the text of the CEVNI rules does state some kind of personal license that involves a practical test is required. However, I'm starting to wonder if *in practice* it's totally ignored by the CEVNI inland waterways people themselves or if you can just get signed off by the local lock keeper or somesuch. [1] That would explain a) the total lack of information on the web about how to get a qualification that satisfies CEVNI if you're not British [0] b) The failure to mention a personal qual in the document above and c) the large number of boats from states that don't issue ICCs cheerfully using CEVNI waters without impediment.

Since nobody here knows I think I *will* fire a mail off and see what's what.

[0] Try googling in any language of your choice - nothing.
[1] Or just hand over a Day Skipper qual and they wave you on. [2]
[2] Or just hand over a Day Skipper qual and they ask you a few verbal questions about the CEVNI rules of the road before waving you on. [3]
[3] Or jump on board go up and down with you driving and then sign you off. [4]
[4] Or something like that.

 

[Tranona]

Just thinking aloud but....

...requirement for ICC+CEVNI seems absent from the information for tourists here (unless navigation permit or sea permit need it):

http://www.vnf.fr/vnf/img/cms/Tourisme_et_domaine/tarif_plaisance_ang_201112131034.pdf

http://www.vnf.fr/vnf/img/cms/Domaine_public_fluvial/hidden/beforeyouleave_200509141429.pdf

Indeed, here it says the requiremnt for qualifications can be waived. No idea if that's relevant, I wonder if some/all waterways waive the requirement for pleasure boats on request?

http://www.unece.org/fileadmin/DAM/trans/doc/finaldocs/sc3/TRANS-SC3-115r2e.pdf

Of course the text of the CEVNI rules does state some kind of personal license that involves a practical test is required. However, I'm starting to wonder if *in practice* it's totally ignored by the CEVNI inland waterways people themselves or if you can just get signed off by the local lock keeper or somesuch. [1] That would explain a) the total lack of information on the web about how to get a qualification that satisfies CEVNI if you're not British [0] b) The failure to mention a personal qual in the document above and c) the large number of boats from states that don't issue ICCs cheerfully using CEVNI waters without impediment.

Since nobody here knows I think I *will* fire a mail off and see what's what.

[0] Try googling in any language of your choice - nothing.
[1] Or just hand over a Day Skipper qual and they wave you on. [2]
[2] Or just hand over a Day Skipper qual and they ask you a few verbal questions about the CEVNI rules of the road before waving you on. [3]
[3] Or jump on board go up and down with you driving and then sign you off. [4]
[4] Or something like that.

Just to avoid you wasting any more of your valuable time the requirement for a certificated formal test is indeed waived in certain circumstances. First, you need to understand that CEVNI does not cover all European Inland waterways and that it is not the same as VNF. The French government waives the need for the formal test for recognised charter operators who instead can conduct an informal test of boat handling and knowledge of the rules before the start of a charter holiday on inland waterways. This exemption is long standing and well known to people who have any interest in the subject.

However, it does not apply to visitors navigating the same waters in private vessels, nor to citizens or residents of the countries concerned using a private vessel. In these circumstances the practical and knowledge certification is required.

You can probably work out why the French government allows this exemption.

You will also find if you follow your own mantra of DYOR (rather than relying on others) that other controlled waterways may have their own specific certification requirements for users.

Please stop "wondering" what happens - that is the root of your problem, you seem to have a fertile imagination which seems to inhibit rational thought.

 

[Bru]

Am I missing something?

Yes

The RYA is a wonderful business model. .... It is a Company Limited by Guarantee, not an arm of the British Government, or a charity, or a professional body. It is simply a commercial entity.

Wrong, wrong, wrong and thrice wrong I say!

A charity is also a company* but unlike the common model of commercial organisation where the liability is limited by shares, the liability in the case of a Company Limited by Guarantee (usually of the members who are jointly and severally liable for the debts of the company) is limited to the amount guaranteed by the members. This amount is almost invariably £1

* or some other form of organisation such as a Trust, Community Interest Company etc.

The RYA is technically a "not for profit" organisation rather than a charity as the directors have chosen not to register the Association as a charity (and have de-registered several subsidiaries which were so registered). Registered Charity status is a two edged sword and all the more so with recent changes. It was never really intended for members interest organisations such as RYA (which isn't registered) or the IWA (which is and of which I am a former trustee)

Registration brings some modest benefits in way of tax breaks but a whole layer of extra regulatory control and, particularly, financial constraints which do not necessarily make a good fit with an organisation which is principally funded by income generated directly by its activities and whose expenditure is, in turn, principally in support of the activities which generate the income!

The charity model (from a legal point of view) is geared towards a> organisations which raise money by appeals and similar fund raising efforts and then spend that income relatively quickly and b> trusts which regularly spend modest amounts of income generated by their original endowment. It isn't actually all that clever for organisations that have significant long term assets and managed investments (a charity is supposed to spend its money forthwith) nor for organisations that trade significantly but do so without paying dividends to shareholders and/or directors (not for profit organisations)

If you are in any doubt about the status of the RYA or any similar organisation, go read the annual accounts and see where the money goes. One thing you will not find on the RYA balance sheet, for example, is un-earned payments to directors (the five non-executive directors of the RYA are unpaid*) or dividends to shareholders (there aren't any shareholders) etc. What comes in goes out on the aims of the organisation and/or admin costs

* the two Executive Directors, who are salaried, were paid £41,900 and £29,220 gross in 2012

 

[toad_oftoadhall]

CEVNI does not cover all European Inland waterways and that it is not the same as VNF.

I assumed VNF waterways were typically governed by the CEVNI rules, is that wrong?

The French government waives the need for the formal test for recognised charter operators

IIRC that's nothing to do with 1.02 - that's specifically written into the CEVNI code itself. Please cite.

You can probably work out why the French government allows this exemption.

IIRC that's not the French Govt 'allowing an exemption'. It's actually written down in CEVNI itself. Please cite.

Please stop "wondering" what happens

I'll wonder whatever I want.